What is the burden of pleading as an affirmative defense that a failure to satisfy a state procedural rule forecloses federal review?

MultiRegion, United States of America

The following excerpt is from Irakunda v. Cates, Case No. 20cv1870-MMA (BGS) (S.D. Cal. 2021):

Respondent has the initial burden of pleading as an affirmative defense that a failure to satisfy a state procedural rule forecloses federal review. Bennett v. Mueller,

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